Archive | April, 2012

U.S. Income Tax: Non-Resident Aliens

April 30, 2012  |   Posted by :   |   International Investors   |   0 Comments

Non-resident aliens are subject to U.S. Income Tax on U.S. source: (1) FDAP Income, (2) Effectively Connected Income. (1) “FDAP” Income U.S. Source “FDAP Income” i.e., Fixed or Determinable Annual or Periodical Income (e.g., salaries, wages, interest, rents, dividends and royalties). A non-resident alien is subject to U.S. federal income tax on FDAP income at […]

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U.S. Income Taxation: Foreign Nationals

April 23, 2012  |   Posted by :   |   International Investors   |   0 Comments

United States taxes “U.S. Persons” on their worldwide income according to IRC §61(A). Under IRC §7701(a)(30) U.S. Persons include the following: (1) U.S. Citizens; (2) Resident Alien Individuals (Green Card Test; Substantial Presence Test, (IRC §7701(b)(1)(A)); (3) Domestic Corporations (Corporations created under the laws of one of the 50 states) – location of corporate headquarters […]

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Key Asset Protection Statutes

April 16, 2012  |   Posted by :   |   Asset Protection   |   0 Comments

For U.S. investments, income tax planning and asset protection may be efficiently accomplished by holding U.S. investments in a One-Member California Limited Liability Company which is owned by a California Trust and managed by a California Corporation. Please see enclosed Key Asset Protection Statutes in California: 1. California Probate Code §18200 If Settlor retains absolute […]

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